20/11/2020
DRAFT/SPECIMEN/FORMAT
(i) Bail Before Arrest
(ii) Bail After Arrest
(iii) Protective Bail
Drafts of All 3 kinds of bail in 1 Post
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PRE-ARREST BAIL:
Pre-Arrest bail was filed before High Court after Learned Additional Sessions Judge dismissed bail before arrest of the petitioner.
BEFORE HONOURABLE LAHORE HIGH COURT, LAHORE.
CRIMINAL MISC. NO:____________________________/B/2015
____, SON OF ____, CASTE ____, RESIDENT OF ____, DISTRICT____.
…..Petitioner
V E R S U S
1. THE STATE
2. ______, SON OF _____, CASTE ___, RESIENT OF ____, DISTRICT____.
…..Respondents
F.I.R. No. : ___/2014
OFFENCE U/S : 406 P.P.C.
DATED : ____
POLICE STATION : _____
DISTRICT : _____
B A I L P E T I T I O N
UNDER SECTION 498 CR.P.C. FOR GRANT OF BAIL BEFORE ARREST TO THE PETITIONER.
Respectfully Sheweth:
1. That through the instant bail petition, the petitioner seeks bail before arrest in case registered through F.I.R No ___/2014 dated _____, under section 406 Pakistan Penal Code at Police Station ____, District ___.
2. That succinctly stated facts giving rise to the filing of bail petition in hand are that aforementioned FIR was registered on the application of the complainant/Respondent No.2/____(name), wherein it has been alleged that the petitioner was entrusted with some amount of the complainant and he misappropriated the same; hence, the FIR was registered against the petitioner. Copy of F.I.R No. ___/2014 dated ___ u/s 406 PPC is appended herewith for kind perusal of this Honourable Court as Annex-A.
3. That the petitioner applied for Bail Before Arrest before Learned Sessions Judge, __, however, same was dismissed vide order dated ___ passed by Learned Additional Sessions Judge, ____. Copies of Bail Petition & order of dismissal dated _____ are Annex-B & C.
4. That the FIR is an outcome of c**k and bull story and local police is after the petitioner to arrest him, whereas, the petitioner has nothing to do with the commission of alleged offence.
5. That the petitioner has been involved falsely in the instant case, therefore, the petitioner humbly seeks indulgence of this Honourable Court for grant of pre-arrest bail iner-alia on the following grounds:
G R O U N D S
a. That the instant F.I.R is false and frivolous having no truth therein.
b. That the petitioner is totally innocent and he has nothing to do with the commission of alleged offence.
c. That the case of the prosecution is based upon malafide.
d. That the real culprit is _____ with whom the complainant has affected compromise and the petitioner is not responsible for any misappropriation as no money was entrusted to him. (this ground depends upon the circumstances of the case).
e. That there is an unexplained delay between registration of FIR and commission of alleged offence.
f. That if the petitioner is released on bail, there is no chance that the petitioner would tamper with prosecution witness.
g. That there is no probability of absconsion of the petitioner if he is released on bail.
h. That in aforementioned circumstances, the instant case appears to be one of further inquiry.
i. That the petitioner is law-abiding citizen of Pakistan and never thinks to take law in his hand.
j. That there are reasonable grounds for believing that the petitioner has not committed any offence.
k. That the petitioner is ready to provide surety bond for the satisfaction of this learned court if the pre-arrest bail is granted to the petitioner.
l. That the petitioner humbly seeks to raise additional grounds at the time of the arguments.
P R A Y E R
In the aforementioned circumstances, it is humbly prayed that the petitioner may kindly be granted bail before arrest.
It is also humbly prayed that till disposal of titled bail petition, interim bail may be granted to the petitioner.
PETITIONER
THROUGH
U. S. M.
Advocate High Court
C.C. NO:P-LH____
Certificate:
It is certified that upon instructions of the client it is the 1st petition for bail before arrest filed before this Honourable Court in the matter in hand.
Advocate
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(ii) Bail After Arrest - Post-Arrest Bail
Bail Petition: 9(C) CNSA
FIR was registered against the petitioner that charas wheighing 1140 grams recovered from him upon raid. Bail petition was dismissed by Sessions Court. Bail was filed before Honourable High Court on the grounds that he was innocent, case was borderline case and the petitioner had no criminal background.
BEFORE HONOURABLE LAHORE HIGH COURT, LAHORE.
CRIMINAL MISC. NO:____________________________/B/2015
___, SON OF ____, CASTE _____, RESIDENT OF ____.
Presently Confined at District Jail _____.
…..Petitioner
V E R S U S
1. THE STATE
2. (COMPLAINANT) A.S.I. POLICE STATION CITY, (COMPLAINANT).
…..Respondents
F.I.R. No. : ___/2015
OFFENCE U/S : 9-C (CNSA)
DATED : 29.03.2015
POLICE STATION : City.
DISTRICT : ____.
B A I L P E T I T I O N
UNDER SECTION 497 CR.P.C. FOR GRANT OF BAIL AFTER ARREST TO THE PETITIONER.
Respectfully Sheweth:
1. That through the instant bail petition, the petitioner seeks bail after arrest in case registered through F.I.R No 387/2015 dated 29.03.2015, under section 9-C CNSA at Police Station City, District ____.
2. That the FIR was registered on the application of the complainant/Respondent No.2/___, wherein it has been alleged that upon raid charas weighing 1140 grams was recovered from the petitioner. Copy of F.I.R along with better copy is appended herewith for kind perusal of this Honourable Court as Annex-A.
3. That the petitioner applied for Post Arrest Bail before Learned Sessions Judge, ___, however, same was dismissed vide order dated 19.06.2015 passed by Learned Additional Sessions Judge, ___. Copies of Bail Petition & order of dismissal dated 19.06.2015 are Annex-B & C.
4. That the FIR is an outcome of c**k and bull story and the petitioner has nothing to do with the commission of alleged offence.
5. That the petitioner has been involved falsely in the instant case, therefore, the petitioner humbly seeks indulgence of this Honourable Court for grant of pre-arrest bail iner-alia on the following grounds:
G R O U N D S
a. That the instant F.I.R is false and frivolous having no truth therein.
b. That the petitioner is totally innocent and he has nothing to do with the commission of alleged offence.
c. That the case of the prosecution is based upon malafide.
d. That as a matter of fact nothing has been recovered fro the petitioner, the alleged recovery is planted one.
e. That the instant case is borderline case.
f. That no private witnesses have been associated with the alleged recovery.
g. That the petitioner is behind the bar for a considerable period of time i.e. about 3 months.
h. That the petitioner is not required by the police for further investigation.
i. That the petitioner has no criminal background.
j. That if the petitioner is released on bail, there is no chance that the petitioner would tamper with prosecution witness.
k. That there is no probability of absconsion of the petitioner if he is released on bail.
l. That in aforementioned circumstances, the instant case appears to be one of further inquiry.
m. That the petitioner is law-abiding citizen of Pakistan and never thinks to take law in his hand.
n. That there are reasonable grounds for believing that the petitioner has not committed any offence.
o. That the petitioner is ready to provide surety bond for the satisfaction of this learned court if the post-arrest bail is granted to the petitioner.
p. That the petitioner humbly seeks to raise additional grounds at the time of the arguments.
P R A Y E R
In the aforementioned circumstances, it is humbly prayed that the petitioner may kindly be granted post arrest bail.
PETITIONER
THROUGH
U. S. M
Advocate High Court
Certificate:
It is certified that upon instructions of the client it is the 1st petition for bail after arrest filed before this Honourable Court in the matter in hand.
Advocate
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(iii) Protective Bail
PROTECTIVE Bail before High Court
BEFORE HONOURABLE LAHORE HIGH COURT, LAHORE.
Crl. Misc. No._____________B/2018
_____SON OF___CASTE____RESIDENT OF _____DISTRICT____
………PETITIONER
Versus
1.The State
2. _____SON OF___CASTE____RESIDENT OF _____DISTRICT____
………RESPONDENT
Case FIR No. 616/17
Dated: 13.08.2017
Offence U/S 324/353 186/224, 225/148 149 PPC1 3/20/65A.O.
Cross Version under section 302/395 PPC
P.S. Sadar Pakpatan
District Pakpatan Sharif
PETITION FOR PRE ARREST/PROTECTIVE BAIL U/S 498 Cr. P. C.
Respectfully Sheweth:
1. That the petitioner seeks protective pre arrest bail in cross version of Criminal Case registered vide FIR No. 616 of 2017 at Police Station Sadar Pakpatan, District Pakpatan. Copies of FIR and cross version are Annex-A & B.
2. That the petitioner is absolutely innocent and has been involved with malafide intention just to blackmail harass and to create inconvenience and the petitioner seeks protective pre arrest bail on the following amongst other ground:
G R O U N D S
a. That the petitioner is absolutely innocent and he has been involved by the mother of the deceased in cross version with malafide and ulterior motive otherwise the petitioner has no concern with the alleged offence.
b. That the deceased were required to the police in a case of decoity and they were hardened and disperate criminal, when the police party readied to arrest them they made straight firing at the police party and police acted in their self defence in this regard FIR No. 616/2017 was lodged by Muhammad Atiq Butt, DSP Mian Chanoo.
c. That the mother of the decoites who is being supported by the political figures of the area has lodged cross version against the petitioner and other police officials with malafide intention and ulterior motive with the object to blackmail and harass the petitioner.
d. That no independent person from the locality has supported false version alleged in cross version and even otherwise the alleged cross version is absolutely false fabricated, after thought and not plausible.
e. That the allegation against the petitioner is absolutely false and fabricated and the same is without substance.
f. That the petitioner is respectable and law abiding citizen and he has nothing to do with the alleged offence.
g. That the petitioner is government employee and is ready to furnish bail bonds to the satisfaction of this learned Court and assure to remain present on each and every date of hearing.
h. That the police of District Pakpatan is bent upon to arrest the petitioner and has surrounded the Distrouct Court of Pakpatan on the instruction of high officials as well as on political influence and pressure and the petitioner is unable to reach the Sessions Court to avail the remedy of pre arrest bail hence the petitioner has preferred the instant petition to seek protective bail and to approach the learned Sessions Court Pakpatan for the appropriate relief.
i. That the petitioner has apprehension of immediate arrest and if petitioner is arrested by the police it will cause great humiliation to the petitioner.
j. That there is no likelihood of absconsion of the petitioner.
k. That under the circumstance narrated above the petitioner is entitled to the grant of protective bail.
PRAYER
Under the circumstance it is respectfully prayed that this petition may kindly be accepted and the petitioner may kindly be allowed the protective bail so that he can file petition for pre arrest bail before the learned sessions Court Pakpatan Sharif.
Petitioner
Through
U. S. M
Advocate High Court
Certificate
Certified that as per institutions this is the 1st protective bail petition filed in the instant matter.
Advocate
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